United States v. Elgin Nat. Watch Co.

SPARKS, Circuit Judge.

The pertinent facts are as follows: On October 11, 1919’, taxpayer’s return was filed for the year ending April 30,1919, showing a tax of $1,094,037.20, and it was paid as follows:

On October 27, 192.0, an amended return was filed showing a tax liability of $988,110.-99, which resulted in the issuance of a certificate of overassessment to taxpayer on October 25, 1922, of $101,741.85, and this amount having been a part of the payment made on September 7, 1920, was refunded to the taxpayer. On August 30’, 1924, taxpayer was notified of a proposed deficiency of $340,-645.44,…